Privacy Policy

This Privacy Notice for GhostEye, Inc. ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://app.ghosteye.ai or any website of ours that links to this Privacy Notice
• Use GhostEye, Inc. A security & awareness training platform for the next generation of AI-derived threats
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@ghosteye.ai.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? In the course of providing security awareness simulation services, we may process certain categories of sensitive information as directed by your organization's security team, including voice recordings, credential submissions during authorized simulation exercises, and facial characteristics used in video simulations. All such processing occurs solely within employer-authorized security awareness programs.

Do we collect any information from third parties? We may collect publicly available professional information from third-party sources as part of our open-source intelligence (OSINT) capabilities, solely for use in authorized security awareness simulations commissioned by your organization.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

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TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

6. PHISHING ALERT BUTTON (PAB) EMAIL ADD-INS

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS NOTICE?

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

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1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us and that your organization provides to us in connection with our security awareness simulation services.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• email addresses
• names and contact information
• reported email content (subject lines, sender addresses, email headers, and email body text submitted through our Phishing Alert Button add-ins)
• reported email attachment metadata (file names, file sizes, and MIME content types only — we do not collect actual attachment file contents)
• user-provided comments and disposition classifications when reporting suspicious emails

Information Provided by Your Organization. When your organization uses our platform for security awareness training, the following information may be provided to us by your organization's administrators:

• Employee directory data (names, email addresses, job titles, department, group memberships) synchronized from your organization's identity provider
• Phone numbers for voice phishing (vishing) simulation campaigns
• Target employee lists for security awareness campaigns

Information Collected During Security Simulations. When your organization authorizes security awareness simulations, we may collect the following information during those simulations:

• Email engagement data (whether a simulated phishing email was opened, links clicked, and timestamps)
• Credentials submitted to simulated phishing landing pages (used solely to assess simulation outcomes and reported to your organization's security team)
• Voice call recordings and transcripts during simulated vishing campaigns
• Video session recordings during simulated deepfake video calls
• SMS message interactions during simulated smishing campaigns

Information Collected from Publicly Available Sources. As part of our OSINT (Open-Source Intelligence) capabilities, we may collect publicly available professional information (such as from professional networking platforms) to enhance the realism of authorized security simulations. This data is collected solely at the direction of your organization's security team.

Sensitive Information. In the course of providing security awareness simulations, we may process voice recordings, credential submissions during authorized simulation exercises, and facial characteristics used in video simulations. All such processing occurs solely within employer-authorized security awareness programs.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Google APIOur use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To conduct authorized security awareness simulations. We process employee information to create and deliver security awareness simulation campaigns on behalf of your organization, including email phishing, SMS phishing (smishing), voice phishing (vishing), and video deepfake simulations.
• To process and analyze phishing reports. When you use our Phishing Alert Button (PAB) add-ins in Gmail or Outlook, we process the reported email content (headers, body, sender, subject) to help your organization's security team identify and respond to phishing threats.
• To provide analytics and reporting. We process campaign event data to provide your organization with campaign metrics and security awareness reports.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Your Organization's Security Team. When you report a suspicious email using our Phishing Alert Button (PAB), the reported email data is shared with your organization's designated security team through our platform for threat analysis and incident response. Campaign simulation results are also shared with your organization's authorized administrators.
• Third-Party Service Providers. We share information with third-party service providers that help us deliver our Services, including AI service providers, voice and speech providers, video simulation providers, SMS gateway providers, identity and directory synchronization providers, and cloud infrastructure providers. These providers process data on our behalf and in accordance with our agreements.
• Analytics Providers. We share limited report metadata (reporter email address, reported sender address, subject line, and report source) with our analytics service for aggregated reporting and platform improvement. Full email bodies and headers are not shared with analytics providers.

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"). As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• AI automation
• AI translation
• Video analysis
• Video generation
• Natural language processing
• Machine learning models
• AI predictive analytics
• AI research

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

6. PHISHING ALERT BUTTON (PAB) EMAIL ADD-INS

In Short: Our PAB add-ins for Gmail and Outlook only access the single email you explicitly choose to report. We collect limited data necessary to process your phishing report and do not access any other emails in your mailbox.

Our Phishing Alert Button (PAB) is available as a Google Workspace add-on for Gmail and a Microsoft Outlook add-in. When you use the PAB to report a suspicious email, the following data is collected from the email you select:

Data We Collect When You Report an Email:

• Email metadata: Message ID, subject line, sender address, date
• Email headers: Routing headers (From, To, Received, Reply-To, Return-Path, Authentication-Results, DKIM-Signature)
• Email body: Plain text and HTML versions of the email content
• Attachment metadata only: File names, file sizes, and content types (MIME types). We do not collect or transmit the actual contents of attachments.
• Reporter identity: Your email address (to associate the report with your organization)
• Report details: Your chosen disposition (phishing, spam, or suspicious), optional comments, and timestamp

Data We Do NOT Collect:

• Other emails in your mailbox (we only access the single email you explicitly report)
• Attachment file contents (only metadata such as file name, size, and type)
• Your passwords, authentication tokens, or login credentials
• Your full name, phone number, physical address, or other personal contact details
• Your IP address, device information, or browser fingerprints
• Browsing history, calendar data, contacts, or any other mailbox data

How PAB Data Is Transmitted and Secured:

All data transmitted from the PAB add-ins to our servers is sent over HTTPS (TLS-encrypted connections). Each request is authenticated using HMAC-SHA256 cryptographic signatures to ensure data integrity and prevent tampering. No user credentials are transmitted or stored by the add-ins.

Optional Email Deletion:

Depending on your organization's configuration, the reported email may be automatically moved to your trash folder after a successful report. This action occurs locally within your email client and is not a server-side deletion.

Google Workspace Add-on (Gmail):

The Gmail PAB add-on uses the following Google OAuth scopes, each necessary for the add-on to function:

• gmail.addons.execute — Required to run the add-on within Gmail
• gmail.addons.current.message.readonly — Required to read the content of the currently selected email when you initiate a report
• userinfo.email — Required to identify your email address as the reporter
• script.external_request — Required to send the report data to our secure backend API

Our use of Google user data complies with the Google API Services User Data Policy, including the Limited Use requirements.

Microsoft Outlook Add-in:

The Outlook PAB add-in uses the ReadWriteItem permission to read the currently selected email message and to optionally move it to trash after reporting. The add-in only activates when you are viewing an email message and only accesses data from that specific message.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

• HTTPS/TLS encryption for all data in transit
• HMAC-SHA256 cryptographic request authentication for our PAB add-ins
• Multi-tenant data isolation ensuring each organization's data is separated
• Centralized secrets management with encrypted storage
• JWT-based authentication and authorization

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at contact@ghosteye.ai.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at contact@ghosteye.ai.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at contact@ghosteye.ai, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at contact@ghosteye.ai. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contact@ghosteye.ai or contact us by post at:

GhostEye, Inc.

169 Madison Avenue

STE 15939

New York, NY 10016

United States

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

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